Loading...
HomeMy WebLinkAbout10-7453UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 ~°~ ,.,,, ~'~ STUART WINNSG, ESQUIRE - ID #45362 c ~ a ~~ ~ LORRAINE DOYLE, ESQUIRE - ID #34576 ~ ~~ Q ~ ~-- ALAN M. MINATO, ESQUIRE - ID #75860 ~S ~~ ~ ~~ CHANDRA M. ARKSMA, ESQUIRE - ID #203437 ~~Z' t;a SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 ~ Q ~,,, MARGUERITE L. THOMAS, ESQUIRE - ID #204460 z~ _~ ~~g ADAM L. RAYES, ESQUIRE - ID #86408 ~ ~ ~ ~~ .. DANIEL S. SIEDMAN, ESQUIRE - ID #306534 `"" JEROME B. BLANK, ESQUIRE - ID #49736 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com Bank of America, N.A. `COURT OF COMMON PLEAS P.O. Box 660694 :CIVIL DIVISION Dallas, TX 75266 €Cumberland County Plaintiff v. - N0. ~~-~~~~ Lisa E. Houck 301 Cheryl Avenue Mechanicsburg, PA 1'7055 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire; Chandra M. Arkema, Esquire; Adam L. Kayes, Esquire; Marguerite L. Thomas, Esquire; Daniel S. Siedman, Esquire and Jerome B. Blank,, Esquire on behalf of the Plaintiff, Bank of America, N.A. in the above-captioned matter. UDREN LAW OFFICEQS, P.C. C~Nr1 S. Sfsdman, Esga~ar PA IC 30653 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. COURT OF COMMON PLEAS ~;~ ~~~ P.O. Box 660694 € CIVIL DIVISION `~= „~,, ~~~ ~z Dallas, TX 75266 ~ rn n ~ ~ ~ ~y Plaintiff € Cumberland County ~ ti E f ~ ~ r ~1,.,.., ~ ~.., ~ ~, v. ~ ~ ~ c- , Lisa E. Houck hh ' , I ~`~ ~~ _~•~ ~ ~ r~ r~`i ry ~ 301 Cheryl Avenue N0. v - ~~~ ~~, Mechanicsburg, PA 17055 ~~ .,_ g ~ ~ -~~ w> Defendant (s ) f - y rv , :-~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 S ~~~ ~~ O~qa' 3 Q~~ ~`~~ ~~as~ ~ AVISO Le han demandado a usted en la Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la Corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la Corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO I1~iEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this action. 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 301 Cheryl Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mechanicsburg COUNTY: Cumberland DATE EXECUTED: 2/9/07 DATE RECORDED: 2/21/07 BOOK: 1982 PAGE: 4190 The legal description of the mortgaged premises is attached hereto and made part hereof:. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 12/2/10: Principal of debt due $134,000.00 Unpaid Interest at 6.750 from 6/1/10 to 12/2/10 (the per diem interest accruing on this debt is $24.78 and that sum should be added each day after 12/2/10) 4,547.28 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $217.60 and that sum should be added on the first of each month after 12/2/10) 997.03 Late Charges (monthly late charge of $37.69 should be added in accordance with the terms of the note after 12/2/10) 113.07 MIP 53.60 Attorneys Fees (anticipated and actual to 5% of principal) 6,700.00 TOTAL $147,015.98 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been . sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A" , and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a tamely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $147,015.98 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. i` ~_-- ~-`-~ Attorney for Plaintiff O~NM 5. Si~dm~n, ~~~ PA I® 3065~~ Al.l.. TIiAT ~ERTJ~IIV ho~uxe aid i~t ~sf ground s~,a~ts in the ~ of A~6echanir~burg, ~aun~ a~ C~rrnberland and State i~f Pennsyh~ania, bounded ar~i a+ibed as fe~sv~s, M w X BirGlNf~llf~G at a paint in: the cud ire an ~s l~or~ sitJe~ t~l ~t~yt Awet~ue; at: canner ~# I_at nc?w ac f~prmerty afi ~tiV'ai€i~n€~ E. C~yur~ir~ ~aY.ndy'~ruyiy#e•;n~jye~pnce alo~+p k~,{.~tdor nth. ey~rnjc~ug,~,a Crne ~y#~p~ktrse~ryyrf A~vye+~nue/~,~Sro~{u~th ~'7 d~e(p~~{~/~ rrtan~te~s+ ~frGw7ty .i~fn~ ~1~~ V~G"lGn{~`it '~~.~~ 'Ye~ lL°~ ~ p~iFE fop 11~GCf~ ~~ ~bV~!iGlgl~ ~i~ Q ~VFGiM~i~ VF6 ~'Y~4AYn ~ ~~ ~iV rsl a argyle aun<ing to the ri~hr, said axle having a radius of €~ €15}leaf. ~e arc dlstenae a~ t~-i+~a and lour-#enths ~~2,4~ lest to a ~it-# in tie' E&a~rn Tine t~# ~1arEh'~fValnu€ Suety tl~nc~ a#an~ the Easte€r~ line of hlt~rttt Walnut Str+est, North 1? degrees 2fl~ ~€racEtes'V~ieet, nineiy_; and fnre-tenths l<g5.5~ le~x ~ a pt~int ~l corner of fe~S n ar I~ o#' Heten Kimntef, tn~ ala~~ fhe line t~f sera land nnuir rx late of 1r4eler- lClrt~rr~et, hfortta ~ degrees East, eig#€{~-#+~tarand ar~te~hs {B~4_~}feel t+o a pa€~t at corner t~#' ~.at now at larrr~ri~ c~# 1+WIlliaen E. ~+.~rlfrt and +uife, aforern~ened; then: s~iang the line Gf said Lt~t no'ar car formerly of Vtifilhan? E. Curte~in and wife, South T~ degrees 36 rnirtutes E-~ost. one hundred slsu~ anti throe-tenths (111.3~~ fast to a prz~n# ~ the Atnrthert~ curb line ra# Sheryl A+uenue; afs~reroen~oned., at ~-itrt arnCl plate cif BEGiNIVIhIG. HAVItVG tft~srexut ereCt9d a t~nFY story br%ctc dv~cellr~g Itnown and nurrr~'e~l as $l~1 Sheryl A~rant~e,. lsheol~anit~sb~rg;, Pennsylvania... PARCEI. ~ 8-22~~'18-16~ Ails ~.~i'~BI~E~ ~tltl>C3 ~~ ~3 8 \~.~,..~a' w_.~I~ ~ ~ °` ~e~vrder ~~ I)~ed.s (2~701053~.r"~T}11E3~7t1'€ Of32.wFL7r32J f~l! ~ ~VL~~7~L~~ @anlc+~fAmerics PRESORT y'am` F~rs7-Class Main llo+rt tt.S. Pnatage~ atX7 P43 ~e #~04A Fens Paid Te~n~caila.. Gf~. J258?#.RO=iE 'Ih'SO ?333 8z5? 374 548 6531 Send /~aYments ~: P,iJ Brx 7522:. W~rs6~ltrx~. OE ig~66B-52:2 send Ca~rrespnndenice ro: PO ~x 5'170, MS SV37~7B 20?OCld3?-T Simi 1~adley, C1y. 83065 lu~~~lu~l~l~~f~~r~+I"111~111~1~~~11~1~~4n1fu11~"N1~~~!'~Ifll Lisa E Houck 3(31 CI-VER'Yl. AidE MECHAN1CSBllRG, PA 17055-3318 Bar~kofAnterica '. FlaMUe Le>Nns A.O. Box ~'~n'~i9~ ~rtPas. TX 752hYi-£x'94 sang ~oy~m+x~ra ra o.o ao~ xs2a2 NVtTrnueu~rlu*a, DE ?38Bb-5222 August 31, 20th Lass E Hauck 301 CHERYL AWE MEGHAtJ1+CSBURG, PA i7®55-331$ Certified Mail: 71b3 8257 1474 5W82 b51x Return Re~ceiot Re~oue$ted Regular Mall Account No.: 87 24 037 3 9 Property Address:. 301 Cheryl Ave Mechanicsburg, PA 17055-3318 Currvent Services: BAG Home Leans Sen+~cing, LP A-CT 9~ [~£?T~~T TA~CE A~T10N TC~ SA~J''E '1~'C~UF? HOME F~C~M Tt~-RECTt:~SIt~RE This is an official notice that the mortaaae on your home is in default. and the lender intends to foreclose. Soeclfic Inforn~ttlon about the nat~j~a_f tie defauk is provided in the attached Hanes The HOMEOWNER'S EMERGENCY MORTGAGE~SS~~~~,G~ P~,QQRAhI'~~~~jIllA~l may a a,~le to help to save your home. This Notice exntains how the praoram works, To see iF HEMAP can help, you must MEET WITH A CONSUMER CREDIT C-OUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NQTIGE. Take this Notle'a$ with you whsle ~+'Sl.li.l129~t with the Counsslina Aaencv The names. addresses and shone numbers of Consumer Credit Counseling Agencies serving your County are lisbsd at the end of thin Notice, K you have any questions. wou may tali the Pennsylvania Hausina Finance Aaencv toll free at 1 800-342-2397. 1Persana witty impaired h~rin a can call 1-717=TBtf-18691 This Notice contains important legal information. ff you have any questions, representatives at the Consumer Credi! Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer, LA NOTIFIGAGION EN ADJUNTO ES DE SOMA IMPORTANCIA, DUES AFECTA SU DEREGHO A CONTINUAR YNIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA. NOTIFIGACI~N OBTENGA UNA TRADUCCIC'!N INMEDIATAMENTE LLAMANDO ESTA AGENCtA {PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NIIMERO MENGiONADO ARRIBA. PUEDE SER ELEGIBLE PARA. UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER"S NAME{S) PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVIGER RaYmat! t,~c[ru[ionc: btake pmr chEdcpagratieia B:.C Hwn=_ Yens Serving, LP + Dzx,l san3 sin + PfaastzancxiAa rurW~e uilh y3wr GayTt3tk F „ IWe nrdr, 418b "~0 ~ ~ r J,. .^;til 'JAL",I IB ~. tYMigY T ~, A-rnrAr ~ lla~er~4 Ins a:i tul~ rrvnlnp, nalrr~ Fi_::Ja+Y. ~3 CNtGi1V8MPS~ .~ ~,.... ~ ,,-.In.~ie.est, rres~estFVr.-rr Ir r ,sslw rMdlrrYagr al rktys Vn Ine man-~. f Gvl~~ r.InRIB~ Kil'7PW ~"s f.Sr~3J~lEr] ~ {},yit" u, I~aC t:PJ9~3 C~ tg 3E`x5 uby #!`&t.. Lisa E Hauck 301 Cheryl Ave ~I~anicsbura. PA 1 71155-3 31 8 872403739 6AC Home Loans Servittng. LP es a subcedary of 3ar~c of Arrenc~, 1~.A. Poease wr4e ~qu- aas~unt namtr- am a'€ rr.s nvi oa*eat~c+clencc. `a,•,. ~~ r.: r><,i^~C yUU ~ (y'P lie 84iy ,7aymenq R'1ty!k:U c+` *fjL'f:~E:~T k?y pSkl/ 1rr~}n7tw .±t4tNUMG:,. &Ii}I~A tt7 ~'aiK~l!C+e, k1W. BLCFA.3 1 t F2: ixSC~St7f f I3 AaaorJrn: P~tumker. 872403739-8 Lisa E Hours 8 aan~ a fr;,r charges lister ~rrnrV: S2.J1fs.08 as of ~ugus. 3~. 2UtU.. 301 Cheryl Ave s~~~a~:.,ti~n~,r,Pr~~eS~att~~s:. Metxaantlcsbur~, PA 17i9ss-33n 8 aatta.~~~^ ~~ euZPa? A(jiA4,~vka~ ill'llt'I'i'l'Ill'rhlllll''i"'lill'iill"'!'llllllil'ilil'iili "~"'~ BAC Home Loans Servicing, LR PO BC1X 15222 ~*^~ Wilmington. QE 19886-5222 7°" 8724L~31398Qb®Ora2D"i8U8Cli)020i8~)8 ~: 58 6 9 90Q 58f:8 °~ 2 ~,©3 ? 3 9i~• Ht}MEt)VMNER'S EMERGENi~Y MQ~RTGA-GE /4iSStSTANCE P'R4GRAM F IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE AGT OF 19$3 {THE '"ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for Thirty 430) days from the date of this Notice. [>urir~ that time you must arrange and attend a"face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY CONSUMER CREDIT COUNSELING AGENCIES - If you meet with r]rte of the consumer credit counseling agencies listed at the end of this notice, the sender may NOT take action against you far Thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated r~nsumer credit counselino agencies for the county in which the propeerty is located ~m set forth at the end of this Notice. it is only necessary to schedule one face_go-face meeting, Advise your lender immediately of your intentions. APPLICATION FQi~t MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your defautt.) if you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance tmm the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sirgn and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this. Notice. Only consumer credit counseling agencies have applicatirxts for the program and they will assist you in submitting a ccxrrplete application to the Pennsylvania Housing Finance Agency, Your application MUST tae filed or postmarked within Thirty {3tl) days of your face-to-face meetir~. YOU FILE YOUR APPLICATION PROMPTLY, 1F YOU FAIL TO DO SO OR tF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINSTYOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Avasiable funds for emergency mortgage assistance are very Ismited. Whey will be disbursed by ttte Agency under the esigibUiry criteria established by the Act. The Pennsylvania Housing Finance Agency has sooty ~6t]) days to make a decision after it receives your app#ication. During ttnat time, no foreclosure proceedings will be pursued against you if you have met the time regwremen*.s set fortn above. You will be notified directly by tl^ie Pennsylvania Housing Finance Agency ~ s:s decision on your application. NOTE: IF YDU .ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURP05ES ONLY AND SHOULD NDT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (ff you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.} NOTICE DF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TD THE REASONS MENTIONED tN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property boated a~ 301 Cheryl Ave ItAechanicsburg, PA 17G55-3318 IS SEF~IC3C.6St-Y IN (7E1=AUl_T because YOU HAVE NDT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: anth3v Charoes: OTl131J2014 51.942.Tt3 s_at~ Charoes: OT10112©1Q ST5.38 E~ttter Char{tes: Uncollected Later Charges: X0.40 Uncollected Costs: 54.04 Partial Payment E3alar~ce: {50.401 TOTAL DUE: 12,018.0$ Y£3U HAVE FAit.ED TG TRICE THE FC3LLOWING ACTION i'Do nr'~ use if not applicabiel BAC horns Loarrs Servicing. LP is a sr>rary of flank rxtArnerica, N.A. ~A-.m~aii use: P*,v~ir.- : r+r e-mail addre a~ Maw wie allavrus m sad ~a intamcntfan an ynur ar~nun*. i_iaa ~ Nauru E-ne . nddr~--s: Maa+r wa paaR your peymertts~ AS accepted pawroernw c~! rx*~ir~ar and Merest xrlir be applied ~ The langesT ranstandir~ insralMerK due. urYass cthervnee axpreagly prrtetstad rx limlt+eci by law. It ywa earhraY> an amount ea ztzaw m year sd~duled marrthly arnaurr. we ~ appFy your payments a~ ~Ilowa: {~} to uAstarr<ingi manttty paymaMS err u.x'ftzar and iRteteS:. fill escrow cieflraencaes, !,fill Isla :hargea and cathar amourrt~ yru srrra in man wi3t your lawn arncs lry? tv reduce the ar~kniing pro;;htam balance o! your Inen Please sper~ry N you want an addit6onal amourstt appied m tutw<re payments, ra9ter than principal reaartian PoaEdared chsrks: Posddamd c9herks ti bw prt~asaed an the date racaeivetl unless a loan cnunselar agnyea „^. honor the date wtirtten an the cJ~erde a~, a candninn cfi:s rc,ynrant plan SOW TO CURE THE DEFAULT - Yau may cure the default wthinTHIRTY {30) DAYS of the date of ih~s rxatice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,018.08 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30} DAY PERIOD. P nts must Ise made either by cashiers check certified check or money order made oavable and sent ta; BAG Home Loans Servicing. LP at P.Q. Box 15222, Wilmington. DE 19886-5222. re any other default_bv_taLna the fulla~ina aduan within THIRTY'3t)) DAYS of the date of this letter fdo not use if n IF YOU DO NOT CURE THE DEFAULT - It you do not cure the default within THIRTY (3Q} DAYS at the date of this Notice, the lender irrtends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due irrtmediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY {34) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. ~, THE MORTGAGE ~ FOR ~{,,,,i~SED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to Its attameys, but you cure the delinquency before the lender begins legal proceedings against you, you wilt still be required to pay the reasonable att~ney"s fees that were actually incurred.. up to ffi5fl.el4. However, h legal proceedings are started against you. you wait have to pay alt reasonable attorney's fees actually incurred by the lender evert if they exceed $54.4Q. Any attorney's fees will tie added to the amount you owe the lender, whicft may also include other reasonable costs. tf you cure the default within the THIRTY {SOj DAY period, you will not be required to pay attorney`s fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NONEXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES -The lender may also sue you persartaily for the unpaid principal balance and all o€her sums due under the morgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - if you have not cured the default witftin the THIRTY X341 DAY period and foreclosure proceedings have begun, you still have the right. to cure The default and prevent file sale at any time up ica one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other casts c~nneoted with the Sheriff's Sale as specified in wrlLing by the lender and by perfarrrting any other requirements underthe mortgage. Curing your default in the manner set forth in this notice will rea#orr your mortgage !a the same pasitian as If you had never defaulted EARLIEST P0331BLE SHERIFF`S SALE DATE -his estemated that the earliest date that such a Sheriff's Saie of the mortgage property could be held would be approximately six (6j months from the date of tilts Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of cxaurse, file amount needed to cure the default wilE increase the longer you welt. You may find out at any time exactly what the required payment or action will tae by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender, 8'AG l#ome Leans Servicing, Lip Address; P, O. Bax 860694 Deltas, TX 752iS6-t-8S4 Phone Number; 7-$00-669b-6GS4 Fax Number: 1-8i7-2~0-88"f7 ~4 ct Person: MS 7X2-9TT-01-13 sttteniron: Loan Counselor Email A~~nsss: To unsure secure email communications please log on to the BAC Hame Loans Servicing, LP Webshe at wwvv.bankofamerica.cam and email us by navigating through the Customer Service link provided EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will erxi your ownership of fire mortgaged propeRy and your right to occxipy it, If you continue to Ilve in the Ixraperty after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lerxfer at any time. ASSUMPTION OF MORTGAGE -You may sell or transfer your home to a buyer ar transferee who will assume the marbgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to ar at rite sale and that the other requirements of the mortgage are satisfied. YQ~~ m,AY ALSO,~jflw~! „~ THE RIGHT: TO SELL.. THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT GU RED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME. POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER. YOU DO NOT HRVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY GA! ENDAR YEAR.} TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TG SUCH ACTION E3Y THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, Your lean ifi in default. Pursuant to your loan documents, BAC Home Loans Servicing, LP may. enter upon arm conduct an inspection of your property. Tate purposes of such an inspection are to ti}observe the phys~cai condition of your property, iii) verify that the property is tSicCUpied andfar (ii{} determine the identity of the occupant. If you drs not cure the default prior to the inspection, other actions let protect the mortgagee's interest In the property (including, but not limited ta, wirtterizatinn„ securing the property. and 3A~ H4me L.oares Servicing. LP is a stlt~diary of dank otAmaria;s. M.A. 73,13 $257 3F4~4 54$2 6S1L valuation services) may be taken. The costs ofithe above-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. !f you are unable to cure the default on or beforE September 30, 2010, BAC Home Loans Servicing, LP wants you to be aware of various options that may be available to you through BAC Home Loans Servicing, LP to prevent a foreclosure sale of your property. For exarrsple: • Repayment Plan:his possible that you may be eligible far some farm of payment assistance through BAC Home Loans Servicing, LP. C)ur basic plan requires that BAC Home Loans Servicing, LP receive, up front, at least '1~ ~ the amount necessary to bring the account current. and that the balance of ttre overdue amount be paid, along wltir the regular monthly payment, rnrer a del#ned period of time. ether repaym$nf plans also, are available. • Laan Modiflcatian: Or, is passible that the regular monthly payments can be lonn+ered through a modification of the loan by reducing the interest rate and then adding the delinquent payments tca the curren# loan balance, This foreclosure alternative, however, is limited to t:ertain ban types, • Sale of Your Property: ter, if you are willirtp to sell your home in order La avoid foreclosure, it is tossible that the sale of your home can be approved through BAC Home Loans Servicing. LP even if your home is worth less than what is awed on i#. • Deed-in-Lieu: Ur, if your property is free from other liens ar encumbrances, and if the default is due b©a seriausfinancial hardship which as beyond your control, you may be +~iigibie to deed your property directly to the rJoteholder and avoid the foreclosure sale. ff you are in#ereSted in discussing any of these foreclosure alternatives with BAC Hame Loans Servicing, LP, you must contact us immediaUely. if you request assistance. SAC Home Loans Servicing, LF' will need to evaluate whetherthat assistancewill be extended to you. in the meantime, BAC Home Loans Servicing„ LP will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise In wrtting, Failure to bring your loan current or to enter into a written agreement by September ~©. 20102 as outlined above will result in the acceleration of your debt Time is of the essences, tt you have any questions concerning this notice, please costa Loan GounseGng Center immediately at 1-$Ot7-f ~ga6654. BAS Name Loans Serviang. LP is a sut~sidiary of Bank at Arne~aa, N.A- 73..13 bc~5'? L474 5482 651E Attachment: Kemization of Charges and Fees M1elor~thty charges: aaat~1r2o1o - o8r~1r2o1o Late Chsrt~es: 07101F~'010 - o8t31,"1010 C9ther Charges: UncoE9ected Late Charges: Partial Payrnerrt E3alance: F~ ~S $sa1.~~ ~1,s~2.~o ~ ~3i.s9 ~?5.38 $0.00 c$o.oati TOTAL iDl.)E: ;2,018,08 BAC Home Loans Servior~, LP s a suckary of Bank of America. ~i.A. CO?kT~i.T'.VIF.R CREDIT C.C}UNSEI..Il'~.~G AGENCIES 5FR~TTNG ~'C)t.TR C(~L~?T~= CUMf3ERLANd COUNTY Pf-€FA Arlrlms Cc~uroty Irtt~rfaith ticausang A~Sx+ty Lrveshi~?, Inc, 211 raoMi Frrxtt Street 4~ 6 High Street 2320 North 5th StrAet Ht~r€istte~g, PA. 17110 Gettyttburg; PA 13325 t-tarristaurg, PA 17110 71? 75£5.:3940 718..334.1518 ?17.232,2208 5'~0 3+s2.2397 CC;~ rd. Yueritem t'A Camrnurrly Acticxt Cpmnns*oicus c1t (.:Ap11Al klae»nattta 2(300 Lsngiestc~wn Rr~dce Regiart d3 Phitetlelpt`we Avarxae Harristlvg, PP, 17102 1514 Ge*ry $tre9t !".'BynBSksor~, PA 182G8 588.511.222? Harrittbtmp, PA 1?104 717.7(32,3'285 t1Es8 511.2227 7i7-232.9757 V E R I F I CAT I O N I, the undersigned, am attorney for the Plaintiff and am authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents. The statements made in the foregoing pleading are true and correct to the best of his/her information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Attorney for Plaintiff t~MiM S. Birdman, Esqu M ID 3O653a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson iff Sh m~-~~'~~ f. ~ ~!' ~3 er ,,~- ! Jody SSmith - Chief Deputy ~~~.i~Q ~}~'~ ~ ~ ~~ ~~ Richard W Stewart Solicitor . ~ ~ ~! r.~~l~~~'c'~ ~';~~~ ; `'' ~; ~_,,~ y ~ " ~ t~ `~ ? v ~ , , Bank of America, NA Case Number vs. Lisa E. Houck 2010-7453 SHERIFF'S RETURN OF SERVICE 12/15/2010 01:18 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 15, 2010 at 1318 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Lisa E. Houck, by making known unto herself personally, at 301 Cheryl Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. r ,~ IC AEL BARRI -K, PUTY SHERIFF COST: $46.00 December 16, 2010 SO ANSWERS, ,, ~~-J'% RONNY R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. P.O. Box 660694 Dallas, TX 75266 Plaintiff v. Lisa E. Houck 301 Cheryl Avenue Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor Defendant (s) Lisa E. Houck for failure Complaint within 20 days from service sale of the mortgaged premises, and follows: As set forth in Complaint Interest Per Complaint From 12/3/10 to 8/26/11 Late charges per Complaint From 12/3/10 to 8/26/11 Escrow payment per Complaint From 12/3/10 to 8/26/11 a N X- --t mrr- -Orn =-n C?-n ? rT1 of the Plaintiff and against the to file'an Answer to Plaintiff's thereof and for foreclosure and assess Plaintiff's damages as ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County c MORTGAGE FORECLO C r- NO. 10-7453 $147,015.98 6,616.26 ?o .-P 339.21 1,740.80 TOTAL $155,712.25 I hereby certify that (1) the addresses of the Defendant are as shown above, and (2) that noti e has accordance with Rule 237.1, a copy of which is aV_ Q*e- UDREN BY: Plaintiff and been given in hereto. Att-rney`s? or Plaintiff Shorrt neg, Esq u ire PA ID 45362 DAMAGES ARE HEREBY ASSESSED AS INDICA D #14.00 PA A7Ty DATE : 0 W7100 01 PRO P HY M,4ee i? =? ,?annidWW fwsu?2 I1 Aq UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Bank of America, N.A. :COURT OF COMMON PLEAS P.O. Box 660694 :CIVIL DIVISION Dallas, TX 75266 Plaintiff :Cumberland County V. Lisa E. Houck 301 Cheryl Avenue :NO. b Mechanicsburg, PA 17055 Defendant(s) C, ZZ 57 COMPLAINT IN MORTGAGE FORECLOSURE rn c? r w c? r- c~) 7. YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and f iling in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL. SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 7 - r SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith V, Chief Deputy :1s"! Richard W Stewart Solicitor Bank of America. NA vs, Case Number Lisa E. Houck 2010-7453 SHERIFF'S RETURN OF SERVICE 12/1512010 01:18 PM - Michael Barrick, Deputy Sheriff, who being duty sworn according to law, states that on December 15, 2010 at 1318 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Lisa E, Houck, by making known unto herself personally, at 301 Cheryl Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. iC AEL BARRI yK, PUTy SHERIFF COST: $46.00 December 16, 2010 SO ANSWERS, h ? J RONNY R ANDERSON, SHERIFF UD'-EN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOC,DCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #10111035-1 Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff ;CIVIL DIVISION V. :Cumberland County Lisa E. Houck Defendant(s) NO. 10-7453 TO: Lisa E. Houck 301 Cheryl Avenue Mechanicsburg, PA 17055 Date of Notice: January 5, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EI\7 ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE.ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Daniel S. Siedman, Esquire PA ID 306534 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. P.O. Box 660694 Dallas, TX 75266 Plaintiff V. Lisa E. Houck 301 Cheryl Avenue Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 10-7453 AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states, upon information and belief, that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Lisa E. Houck Age: Over 18 Residence: As captioned above Employment: Unknown This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Title. Company : Shwt Winneg, Esquire A ID 45362 J? Aq UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Lisa E. Houck :NO. 10-7453 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due Interest From 8/27/11 to Date of Sale December 7, 2011 Ongoing Per Diem of 24.78 to actual date of sale including if sale is held at a later date (Costs to be added) 44.00 PO A-17Y UDREN 4(0.00 LSF" 9x.00 " 1'/.00 " 9.50 BY: At r: $178.50_ PO AT*rY a -00 NW& • so U. c 14114 Q,? ?la3glD 2,552.34 ?OF P.C. zeys for Plaintiff Stuart Winneg, Esquire PA ID 45362 C C ? -n - G1 0M -<rv o° r _. --+o 3 6-n X CD t ?7 C3 n ,,-yi'T'i $155,712.25 I E tor it Imud I AQ UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank F A FOR PLAINTIFF o merica, N.A. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V =Cumberland County -?3 MORTGAGE FORECLOSURgrn air- Lisa E. Houck :`-NO. 10-7453 -<>> Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The jud A. B. X C. D. gment entered in the above matter is b In Assumpsit (Contract) In Trespass (Accident) In Mortgage Foreclosure On a Note accompanying a purchase property being exposed to sale is hJ O a C tV Q N CD -,.3 --+ =-n rnr - - -0M 00 -!p s -? cJ-n W - E5 C7 m --f ased on an Actidn:-C+ --e money mortgage and the the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X -A. B. C. Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of Pennsylvania If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: Stuart Winn Rod Winneq, F, PA ID 45362?? PA Tn Attorneys for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. :COURT OF COMMON PLEAS n - 3 T1 Plaintiff :CIVIL DIVISION 0 M C= r, V. ':Cumberland County = X;o G1 o :MORTGAGE FORECLOSURE 3• =Q - ca n --- :zc) can Lisa E. Houck :NO. 10-7453 N ', Defendant(s) we ?' C E R T I F I C A T E I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 36 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFJZES _-7P . C . BY Atto,vheys for Plaintiff Stuart Winneg, Esquire PAID 45362 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. -COURT OF COMMON PLEAS n o Plaintiff CIVIL DIVISION 3 --e V. € Cumberland County rrn m"' rrn--'` 2 G-1 -0m =MORTGAGE FORECLOSURE ,r C) Lisa E. Houck € N0. 10-7453 ?? 3>c" y' a? Defendant (s) ) C:) Z o z_. Cl) ? N y AFFIDAVIT PURSUANT TO RULE 3129.1 C Bank of America, N.A., Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 301 Cheryl Avenue, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Lisa E. Houck 301 Cheryl Avenue Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of of record: Name Bank of America, N.A. the last recorded holder of every mortgage Address P.O. Box 660694 Dallas, TX 75266 Blazer Consumer Discount Co. 1217 Market Street, Lemoyne, PA 17043 Household Realty Corporation 6106-H Jonestown Road Colonial Commons, Harrisburg, PA 17112 r 1 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, Pa 17013 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 301 Cheryl Avenue Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: August 26, 2011 LAWQV.PiCES, P.C. wart Wfnn", Esquire BY. PA ID 4536? Atto, eys for Plaintiff SWOrt "nneg, Eso,,ir PA ID 4C 1 w, UHREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION V. ::Cumberland County :MORTGAGE FORECLOSURE Lisa E. Houck NO. 10-7453 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lisa E. Houck 301 Cheryl Avenue Mechanicsburg, PA 17055 C-) G rnC0 =rn Z;3 r ?-= CC:? = p --c rJ CJ C c? N t,D 3 G' rn r, -urn O o'° =o C-') Z n C:>m Your house (real estate) at 301 Cheryl Avenue, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 7, 2011, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $155,712.25, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Lisa E. Houck Defendant(s) :NO. 10-7453 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Lisa E. Houck PROPERTY: 301 Cheryl Avenue, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 7, 2011, at 10:00 am, at the Commissioners hearing Room, 2nd Floor Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATE IN THE BOROUGH OF MECHANICSBURG, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CURB LINE ON THE NORTH SIDE OF CHERYL AVENUE, AT CORNER OF LOT NOW OR FORMERLY OF WILLIAM E. CURTIN AND WIFE; THENCE ALONG THE NORTHERN CURB LINE OF CHERYL AVENUE, SOUTH 77 DEGREES 55 MINUTES WEST, SIXTY-ONE AND ONE-TENTHS (61.1) FEET TO A POINT; THENCE BY THE SAME IN A NORTHWESTERLY DIRECTION BY THE ARC OF A CIRCLE CURVING TO THE RIGHT, SAID CIRCLE HAVING A RADIUS OF FIFTEEN (15) FEET, THE ARC DISTANCE OF TWENTY-TWO AND FOUR-TENTHS (22.4) FEET TO A POINT IN THE EASTERN LINE OF NORTH WALNUT STREET; THENCE ALONG THE EASTERN LINE OF NORTH WALNUT STREET, NORTH 17 DEGREES 20 MINUTES WEST, NINETY-FIVE AND FIVETENTHS (95.5) FEET TO A POINT AT CORNER OF LAND NOW OR LATE OF HELEN KIMMEL; THENCE ALONG THE LINE OF SAID LAND NOW OR LATE OF HELEN KIMMEL, NORTH 77 DEGREES EAST, EIGHTY-FOUR AND ONE- TENTHS (84.1) FEET TO A POINT AT CORNER OF LOT NOW OR FORMERLY OF WILLIAM E. CURTIN AND WIFE, AFOREMENTIONED; THENCE ALONG THE LINE OF SAID LOT NOW OR FORMERLY OF WILLIAM E. CURTIN AND WIFE, SOUTH 12 DEGREES 35 MINUTES EAST, ONE HUNDRED ELEVEN AND THREE-TENTHS (111.3) FEET TO A POINT IN THE NORTHERN CURB LINE OF CHERYL AVENUE, AFOREMENTIONED, AT THE POINT AND PLACE OF BEGINNING. HAVING THEREON ERECTED A ONE STORY BRICK DWELLING KNOWN AND NUMBERED AS 301 CHERYL AVENUE, MECHANICSBURG, PENNSYLVANIA. PARCEL 18-22-0519-165 AS DESCRIBED IN MORTGAGE BOOK 1982 PAGE 4190 BEING KNOWN AS: 301 Cheryl Avenue Mechanicsburg, PA 17055 PROPERTY ID NO.: 18-22-0519-165 TITLE TO SAID PREMISES IS VESTED IN LISA E. HOUCK (A MARRIED WOMAN)BY DEED FROM RONALD E. HOUCK JR. (A SINGLE MAN) DATED 2/9/2007 RECORDED 2/21/2007 IN DEED BOOK 278 PAGE 4180. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-7453 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A., Plaintiff (s) From LISA E. HOUCK (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $155,712.25 L.L.: $.50 Interest from 8/27/11 to Date of Sale 12/7/11 Ongoing Per Diem of $24.78 to actual date of sale including if sale is held at a later date -- $2,552.34 Atty's Comm: % Atty Paid: $178.50 Plaintiff Paid: Due Prothy: $2.00 Other Costs: Date: 8/29/11 (Seal) RFgUESTING PARTY: Name: STUART WINNEG, ESQUIRE Address: UDREN LAW OFFICES, PC David D. Buell, Prothonotary Deputy WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, N X 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 45362 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?taitG?'q p? , r I F } 1 tj?Lii_te y L' Jody S Smith Chief Deputy Richard W Stewart Solicitor Bank of America, NA vs. Lisa E. Houck Case Number 2010-7453 SHERIFF'S RETURN OF SERVICE 09/27/2011 04:00 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 301 Cheryl Avenue, Mechanicsburg, PA 17055, Cumberland County. 09/27/2011 04:00 PM - Deputy Ryan Burgett, being duly sworn according to law, attempted service to the Defendant, to wit: Lisa E. Houck at 301 Cheryl Avenue, Mechanicsburg Borough, Mechanicsburg, PA 17055. The address was found to be vacant. 12/07/2011 Ronny Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County,Pa. on December 7, 2011 at 10 a.m. He sold the same for the sum of $1.00 to Attorney Mark J Udren, on behalf of Federal National Mortgage Association at 1900 Market Street, Suite 800, Philadelphia, PA 19103. Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of $967.84. 01/12/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. SHERIFF COST: $967.84 SO ANSWERS, 6? January 13, 2012 RON R ANDERSON, SHERIFF 'UDREN LAW OFFICES, P.C. 'ODCREST CORPORATE CENTER 111 WOODCRBST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-665-5400 nleadincrs@udren. coin EanK o? America, N.A. Plaintiff t% . Defendant(s) ATTORNEY FOR. PLAINTIFF COURT OF COMMON PLEAS =CIVIL DIVISION Cumbe:-land County :MORTGAGE FORECLOSURE N0. ?0-7453 AFFIDAVIT PURSU_AN'T TO RULE 312 9 . 1 Dan-K- O?= America, N.A. , Plaintiff in Ile above action, by its atcorn??y , Udren Law Off ices , P . C . , sets f: orth as of the date the Praec-..oe for the Writ of Execution was filed the fo-7 owinc i nfo--.:,,ation concerning the real proper--y located ate- : 30--, Cheryl Aven--ie, Mechanicsburg, PA 17055 a.. Name and address of Owner (s' or -e-Du- ed Owner (s Name Address - ism E. liouch 301 Chervl Avenue Mechanicsourg, PA 17055- ? . Name and address of Defendant,; s) in the j udgme= : Iv arr,E_ Address, SAM-71; AS #1 ABOVE !'game and addreSS of eve yr j 1. dgmen- ' `Cr GJ AOS e 7 uu^i? eilt 1S a record lien on the meal proaertv -E-- be sold: 'yam. Address Non E 4. Nam and address of the last recoraed holder every mortgage _ record: Nam--- Address _anj. America, N.A. ??. Bo:,: 660694 Dallas, TX 75266 8..._?ser Consumer Discount Cc. Mawr};et St_Pe_ Lemoyne, pp 17043 asehcld Real(,,- Corporation 6106-1-: Jonestown Rc,ad Cc"cr__.al Commons Pz, Name and address of every other person who has and- record lien on the x) ,_-operty : Name Address None 6. Name ind address of every other person who has any record interest :.n the property and whose interest may be affected by the sale Name Address Real Esta :?e Tax_ Dept Domestic i..elations Section Commonwea: `..h of PA, Department f: Revenue 1 Courthouse Scmare Carlisle, Ps. 1''Oi3 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Bo1: 231230 Harrisburg, PA 17128-1230 7. Name a-,.---, address of every other person of whom the plaintiff has f:nOG91e?'?Te who has anv interest in the -oroX>erty which mat be affected L:- the sale: Name Address Tenants,Oc:apants 301 Cheryl. Avenue Mechanicsburg, P?- 17055 T ve?_ ?t..t the statements made _n this affidav? are :.-_-u= and correct `o the best of my persona'., knowledge o:' inzormal__ ,= and belief. I understand that false statements herein are made subject o the penalties of 18 Pa.C.S. sec. 4914 relating to unsworn fal:.J_fication to authorities. DATED : kucT :s t 2 6 , 2 011 JDREN LAW 1 ES , P. C Stuart Winneg, Esquire DY : PA ID 4536? Attornevs fo:- Plaintiff Stuart Winneq; Esn, r. PA M 4 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER. 111 WOOD-REST ROAD, SUITE 200 CHERRY ?ILL, NJ 08003-3620 856-669-54E00 pleadings@udren.com Bank of ??merica, N.A. `COURT OF COMMON PLEAS Plaintiff = CIV?:L DIVISION Cumberland County :MORTGAGE FORECLOSURE Lisa- E. Houck: NO. 10-7453 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: 7 ?. E. Houc}, 301. Cheryl Avenue Mec:nanicsburg, PA 17055 Your noi:._;e (real estate) at 301 Cheryl :.venue, Mechanicsburg, PA 17055 is sc'rneduled to be sold at the Sheriff's Sale on December 7, 20-._1 at 10:00 am in the Commissioners Hearing Room., 2nd Fioo""I., C'_-)urthouse, Carlisle, PA , to enl"o_"ce the court _Iaacrment of S1.55 "'12.25, obtained by Plaintiff above (the mortgagee) against ou. --_ the sale is -costnoned, the property vi be reliste ! for the Next Available Sale. - r NOTICE OF OWNER'S RIGHTS YOLT YAY BE ABLE TC PREVENT TKIS SHERIFF'S SALE Tc nrever-: this Sheriff's Sale, you must take immediate action: TnE .ale w=_- he cance_1ea _ you Day tc the mcrtgagee the ra'::,_ pav-ment, .mat :_ charges, costs and reasonable attorney- s fees. To find ou-, now mu-_ you must pay, you may call: (8561 66Q-5400. . -Yot may be able to stop the sale by s Dina a x)etition ask_nc Lne Court _--r1ke or oper_ the judgment, if the judgment was improperl--.? entered. Yo ;tat- also ash the Court z_c 'aostpone the= sa__e for good cause. ?. Yol :?a?- also be able to stop tine alp through other legal proceedings. 'Yo,, ta} need an attorney to asse_ your The soone:' contact One. the mcr_ chance you w-11 nave o stc.7TJ:.n(, the sale. See notice on pap- twc or. now to obtain an attorney- - - YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stoppec., vcur property ti be sold to th_ hL:,-ilest bidder. You may find out the price rid by calling E'56-669- 540C. You may be able to petition the Court tc set aside the sale the bid p,_ice was Grossly inadequate compared to the value of your property.-. 3. The sale will go through only if the buyer pays the Sheriff the full amour.-, due in the sale. To find out 1_1 this has happened, vot, may call 856-66 ^-5406. 4. L the amount due from the Buver is not paid to the Sher_ _, you wi_ rema:;n the owner of the property as if he sal never happened. You have the right to remain in the property until tfu=-. amount he due is paid to the Sheriff and the Sheriff gives a c.eed to the bL!v<_:: At that time, the IDUVer may bring legal proceedings zo evic*_ you. C. You may be entitled to a share of the money which was a.id :o,-- your nous A schedule of distribution of the mone-, bid for vour house will be tiled r_.;- the Sheriff within 30 days after the sale. This schecul_: wLi state whc be receiving that money. The money will be paid out accordanc with this schedule unless exceptions (reasons why the proposed dlstrlnUt:ion is wrong) are tiled with the Sheriff w,thln ten (111, days after Sched•._.ie Distribution is filed. You may also have other ,rights a:nd defenses, or wavy czett:_ng your home iDacrc, you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Associa--ion 2 Liberty Avenue Carlisle, P.A. 1701= 717--249-3166 800--990-9108 ASSOCIATION DE ?ICENCIDADOS Cumberland County Bar Associa-_icn 2 Liberty Avenue arl-L s I e PA _701_ 7'17-249-3160" 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, Nj 08003-3620 856-669-5400 pleadings@udren.com Bann of America, N.A. ;COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION Cumberlane County MORTGAGE FORECLOSURE Lisa Houck NO. 10;_7452 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lira E. Houck 3C'. Cheryl Avenue Mechanicsburg, PA 17055 Your house (real estate) at 301 Cheryl Avenue, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale or. December 2011, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA to enforce the court udgment of $15_,,712.25, obtained by Plaintiff above (the mortgaaee; acFai.ns-Y vou. If the sale is postponed, the property- be ,?e1is-ed for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YO'J MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE Tc nre-%,enc this Sheriff's Sale, you must take- immediate action- - -1 sale. w: ? be canoe-lee: if doti Na_ , .o the mcrtgageE -n° ract? pa ,c ent -ace charaes, costs and reasonable attorne,,"s fees. ___ fin out now much vo-:. must pay, you may caL: (E'56) 666-5400. ?. Y?Ol: may be able to stop the sale bv_ oiling a petition as?.4nc the Court strike or open the judgment, ?_ the -iudgment was improkerl- entered. ?:ou may also ask: the Court to postpone the sale for good cause. ou may also be able to stop the sale thrcua." oche'.: 1eGa- proceedings. 'tou may need an alto:~ney tc assert. yoi-r rights- The soorier -ou contact: one, the more chance you w:i1_ have o`_ stox>pina the sa-?--. See no ice on ?:aae cwc on how to obtain are attorney YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. ?. If the Sheriff's Sale is not stopped, your property wil_' be sold to the n_-rT.est bidder. You may find out the price bid by calling 256-669- 540? . You may be able tc petition the Court to set aside the sale i= the bit pr_- ce wa.s grossly- inadequate compared to the value of your prope.-?, _ The sale will go through only if the buyer pays the Sher`- the fuel amount: due in the sale. Tc find out if this has happened, +7o,- ma,,, call 850-66?-54'x: _ the amount due from the Buyer is not paid :.o the Sheri f , you wile. remaii the owner of the property as if the sale never happened. S. zou have the right to remain in the propez-7y until the fu_ - amount due is uaic -_o the Sheriff and the Sheriff gives a deed to the buver. A: that time, barer may bring legal proceedings to evicz you. 6 Y.?u may be entitled to a share of the moneti which was _aic for your house. A schedule of distribution of the money bid for vour house will be filed bti --he Sherif_ within 3C days after the sale. This schedule w- --s-ate whc w._- be receiving that money. The money wil- be paid out __ accordance v.-.:h this schedule unless exceptions (reason:, why the proposed dist.rizutior. is wrong) are filed with the Sheriff witn:n ter( (10,' aavs after Schedule 7,f ,_.:_stribution is filed. may also have other rights and defenses, o,-- ways of ae7?: ng your home ba _t you act immediately after the sale. YOU SHOUL=- T2aE THIS PAPER TO YOUR LAWYER AT ONCE. IF :IOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFF-CE LISTED BELOW TO FIND OUT WHEFE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Associa•_ior_ 2 Liberty Avenue Carlisle, PP. 170--3 77-249-3166 800-990-9108 ASSOCIATION DE LICENCDADOS Cumberland County Bar Association. 2 Liberty Avenue Carlisle PA 170",-_71-,-249-3166 80C-990-9108 ALL THA CERTAIN HOUSE AND LOT OF GROUND SI'T'UATE IN THE BOROUGH OF MECH;.NI,CSBURG, COUNTY OF CUMBERLAND, AND STATE OF PENNSi`LVAIJIA, BOUNDED AND DESCRIBED AS FOLli OWS, TO WIT BEGINNII? AT A POINT IN THE CURB LINE ON TH,- NORTH SIDE OF CHERYL AVENUE, 7J'r CORNER OF LOT NOW OR FORMERLY Or WILLIAM E. CURTIN AND WIFE, THENCE ALONG THE: NORTHERN CURB LINE OF CHERYL AVENUE, SOUTF 77 DEGREES 55 MINUTES WEST, SIXTY-ONE AND ONE-TENTHS (61.1) FEET TO ?:. POINT; THENCE BY THE SAME IN A NORTHWESTERLY DIRECTION BY THE F.RC OF A CIRCLE CURVING TO THE RIGHT, SAID CIRCLE HAVING A RADIUS -71 FIFTEEN (15) FEET, THE ARC DISTANCE OF TWENTY-TWO AND FOUR- TEY THS (22.4) FEET TO A POINT IN THE EASTERN LINE OF NORTH WALNUT STREET; THENCE ALONG THE EASTERN LINE OF NORTH WALNUT STREET, NORTH 17 DEGREES 20 MINUTES WEST, NINETY-FIVE AND FIVETENTHS (95.5) FEET TO A POINT AT CORNER OF LAND NOK OP LATE OF HELEN KIMMEL; THENCE ALONG THE LINE OF SAID LAND NOW OP LATE OF HELEN KIMMEL, NORTH 77 DEGREES EAST, EIGHTY-FOUR AND ONE- TENTHS 8 } . ?) FEET TO A POINT AT CORNER OF :SOT NOW OP. FORMERLY OF WILLIAM E. CURTIN AND WIFE, AFOREMENTIONED; THENCE ALONG THE LINE OF SAID LOT NOW OR FORMERLY OF WILLIAM E. CfJRTIN AND WIFE, SOUTH 12 DEGREES 35 MINUTES EAST, ONE HUNDRED ELEVEN AND THREE-TENTHS (111.3) FEET TO A POINT IN THE NORTHERN CURB LINE OF CHERYL AVENUE, LFOREMENTIONED, AT THE POINT AND PLACE OF BEGINN_NG. HAVING THEREON ERECTED A ONE STORY BRICK DWELLING KNOWN, k=, NUMBEREI AS 30- CHERYL AVENUE, MECHANICSBURc': PENNSI'LV_ -7 . PARCEL 1 22-0519-165 AS DESCRIBED IN MORTGAGE BOOK 1.982 PAGE 419(' _j BEING KSCWN AS: 301 Cheryl Avenue Mechanicsburg, PA 17055 PROPERTY ID NO.: 18-22-0519-165 TITLE T: SAID PREMISES IS VESTED IN LISA E. HOUCK (A MARP!= WOMAN ,? Bt DEED FROM RONALD T. '40771" JP. ;'L SINGL,E.. M.TZ \j) i ,<TE 2;19,'2007 RECORDED -1/21/20C'-/ IN DEED BOOK; 272 PAGE 4180 . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUN" Y,OF CUMBERLAND) 1v 0 10-7453 Civil CIVIL ACTION -- L,,-,kW TO TH'- SHERIFF OF CUMBERLAND COUNTY: To -satisfy the debt, interest and costs due BANK OF AMERICA, N.A., Plaintiff (s) From LISA E. HOUCK (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) Yc 1.j are also directed to attach the property of the defendant(s) not evied upon in the possession of GARNISHEE(S) as follows: and to nx fy the garnishee(s) that: (a) an. attachment has been issued; (b) the garnishee(s) is enjoined from paying ?n?V debt to or for the account of the defendant (s) and from delivering any property of the defendant (s, or of ierwise disposing thereof; (31 If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishc,° and is enjoined as above stated. Amount Due: S155,712.25 L.L.: S.50 Interest from 8/27/11 to Date of Sale 12/7/11 Ongoing Per Diem of S24.78 to actual date of sale including if sale is held at a later date -- 52,552.34 Atty's C ? unm: % Due Prothy: S2.00 Atnv Paid: S178.50 Other Costs: Plaintiff Paid: Date: 8 29,111 Ley David D.?Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name: STUART WINNEG, ESQUIRE Address UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 1 I I WOODCREST ROAD, SUITE 200 CHERRY HILL, NUJ 08003-3620 Attorney iur: PLAINTIFF TRUE COPY FROM RECORD In Tes*nony whereof, I here unto set my hand ` and the seat of said Qw?rt at Carlisle, Pa. 20 !, tc. ??(.y Prothwnotary Telephorne: 856-669-5400 Supreme Court ID No. 45362 On September 2. 20 1 1 I'lle r t i iu [co upon II-I", defendant's interest in tic t"ea pi?opell, srLuated Jii Mechanicsburg Borough, t_;urnberlaria (,.;ounty. PA, Known and numbered as. 30 i Chery i Avenue, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein, Date September 2, 201 Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-7453 Civil Bank of America, NA vs. Lisa E. Houck Atty.: Mark J. Udren ALL THAT CERTAIN house and lot of ground situate in the Borough Of Mechanicsburg, County of Cum- berland, and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the curb line on the north side of Cheryl Av- enue, at corner of lot now or formerly of William E. Curtin and wife; thence along the northern curb line of Cheryl Avenue, South 77 degrees 55 min- utes West, sixty-one and one-tenths (61.1) feet to a point; thence by the same in a northwesterly direction by the arc of a circle curving to the right, said circle having a radius of fifteen (15) feet, the arc distance of twenty- two and four-tenths (22.4) feet to a point in the eastern line of North Wal- nut Street; thence along the eastern line of North Walnut Street, North 17 degrees 20 minutes West, ninety-five and fivetenths (95.5) feet to a point at corner of land now or late of Helen Kimmel; thence along the line of said land now or late of Helen Kimmel, North 77 degrees East, eighty-four and one-tenths (84.1) feet to a point at corner of lot now or formerly of William E. Curtin and wife, afore- mentioned; thence along the line of said lot now or formerly of William E. Curtin and wife, South 12 degrees 35 minutes East, one hundred eleven and three-tenths (111.3) feet to a point in the Northern curb line of Cheryl Avenue, aforementioned, at the point and place of BEGINNING. Having thereon erected a one story brick dwelling known and numbered as 301 Cheryl Avenue, Mechanics- burg, Pennsylvania. PARCEL 18-22-0519-165. As described in Mortgage Book 1982 Page 4190. BEING KNOWN AS: 301 Cheryl Avenue Mechanicsburg, PA 17055. PROPERTY ID NO.: 18-22-0519- 165. TITLE TO SAID PREMISES IS VESTED IN Lisa E. Houck (a Mar- ried Woman) by Deed from Ronald E. Houck Jr. (aSingle Man) Dated 2/9/2007 Recorded 2/21/2007 In Deed Book 278 Page 4180. 44 J The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg,, PA 17050 Inquiries - 717-.255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERI-,ND COUNTY COURT HOUSE Z4tPatriot News Now you know CARLISLE: PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain. being dluly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot News Co. aforesaid by virtue and pursuarri to a resolution unanimously-passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14., Page 317. .PUBLICATION COPY This ad ran on the date(s) shown below: 10/21/11 10/28/11 11/04/11 Sworn to a subscribed-before mb thA_ 1G y of November, 2011 A.D. ? r 4 !i Notary Public - COMMONWMTH OF ?v n var?u+ ii S? L. Owens, Notary Public N7ASSOCIATION Seal lower Paxton Dauphin County PAY COMMISSioes Nov. 26, 2015 r1EMBER, =, PENNSYLVANIA OF NOTARIES euc Paftiot-Xims Now you know P. O. BOX 2265 HARRISBURG, PA 17105 (717) 255-8237 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle, PA 17013 ACCT. # Date 10/21/11 Sheriff Sale 10/28/11 Sheriff Sale 11/04/11 Sheriff Sale Notary Fee DUPLICATE BILL e # Size Rate 7453 9.22 $12.00 7453 9.22 $12.00 7453 9.22 $12.00 TOTAL DUE FOR THIS SALE: 2260 Net Coy Of Ad $ 110.64 $ 110.64 $ 110.64 $500 $ 336.92 JLC UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank = America, N.A. COURT Plaintiff :CIVIL County Lisa Houck ATTORNEY FOR PLAINTIFF OF COMMON PLEAS DIVISION Cumberland Defendant (s) : NO. 10-745:: ASSIGNMENT OF SHERIFF'S SALE BID 1. U_ren Law Offices, PC is the At:.orriey acting on behalf of Bark of America, N.A., Plaintiff/Bank, crn t-ie Writ of Execution, in oniection with a Mortgage Foreclosu--e a--tion as captioned above. 2. 7-,, the Sheriff's execution sale, Udren Law Offices, PC was the su ,:essful bidder on behalf of Bank of ."..merica, N.A., PIa nt f/Bank. 3. U iren Law Offices, PC, being authorize,] to do so, herek>v assign.; the bid to Federal National Mortgage Association, Assign-= , whose address is 1900 Market Street, Suite 800, Philad?:,=_phia, PA 19103 and instructs the Sheriff, upon payment of the :osts of settlement, to record said Sheriff's Deed in favor, said Assignee. Respectfully submit=ted: UDREN LAW OFFICES, P.C. BY: Alan ?A. Miratc -7' . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: 1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Federal National Mortgage Association is the grantee the same having been sold to said grantee on the 7 day of December A.D., 2011, under and by virtue of a writ Execution issued on the Z9 day of August, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 201.0 Number 7453, at the suit of Bank of America, N.A. against Lisa E. Houck is duly recorded as Ir strument Number 201202272. IN TESTIMONY WHEREOF, I have hereunto set my hand and,?eal of said office this _ day of A.D. a Recorder of Deeds Recorder of Des, Cumbedand County, Cadisie, PA My Commission Expires the ft Monday of Jan. 2014 2010-7483 CWN Term Bank of Ammica, NA V3 LJaa L Houck Attlr: Marls d !!iron All That Certain House And Lot Of GrouM Situate In The Borough Of Mechanicsburg, County Of Cumberland, And State Of Pennsylvania, Bounded And Described As Follows, To Wit: Beginning At A Point In The Curb Line On The North Side Of Cheryl Avenue, At Corner Of Lot Now Or Formerly Of William E. Curtin And Wife; Thence Along The Northern Curb Im Of Cheryl Avenue, South 77 Degrees 55 Minutes West, Sixty-One And One-10nths (61.1) Feet To A Point; Thence By The Same In A Northwesterly Direction By The Arc Of A Circle Curving To The Right, Said Circle Having A Radius Of Fifteen (15) Feet, The Arc Distance Of Twenty-Two ` And Four-Tenths (22.4) Feet To A Point In The Eastern lane Of North Walnut Street; Thence Along The Eastern Lane Of North Walnut Street, North 17 Degrees 20 Minutes West, Ninety Five And Fivetenths (95.5) Feet To A Point At Corner Of Land Now Or late Of Helen Kimmel; Thence Along The Line Of Said Land Now Or Late Of Helen Kimmel, North 77 Degrees East, Eighty-Four And One-Unths (84.1) Feet 1b A Point At Cotner Of Lot Now Or Formerly Of William E. Curtin And Wife, Aforementioned; Thence Along The Line Of Said W Now Or Formerly Of Wiliam E. Curtin And Wife, South 12 Degrees 35 Minutes East, One Hundred Eleven And Three Tenths (111.3) Feet 1b A Point4 In The Northern Curb Line Of Cheryl Avenue, Aforementioned, At The Point Ane Place Of Beginning. Having Thereon Erected A One Story Brick Dwelling Known And Nun.bered As 301 Cheryl Avenue, Mec.anicsburg, Pennsylvania. Parcel 18-22-0519-165 As Desch In Mortgage Book 1982 Page 4190 Avenue Medvoicabn Pa 17055 Property Id No.: 18.22&19-165 T"rth; TO Said Premisos Is Vested In Lisa E. H,)wk (A Married Woman) By Deed From Ronald Ii Houck Jr. (A Single Man) Dated 219/:107 Recorded 2121!2007 In Deed Book 278 Fage 4180. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 21, October 28, and November 4, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyn , Editor SWORN TO AND SUBSCRIBED before me this 4 da of November 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014